Page 22 - Louisiana 811 Magazine 2022 Issue 3

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b. Example: Mandatory reporting of damages is only required for natural gas and hazardous liquid assets.
3. Stakeholder Dissatisfaction with 811 System:
a. Louisiana stakeholders are dissatisfied with 811 system enforcement and performance metrics. Locators are particularly dissatisfied.
b. The frequency of Unneeded Locate Requests, Poor Instructions, and Destroyed Marks are rated as occurring daily and fall into the 4th Quartile.
c. The Louisiana 811 process is missing white lining and electronic positive response and is inefficient in terms of the number of process touches, number of process steps, and the speed and timeliness of the damage adjudication process.
4. Limited Excavator Guidance:
a. No excavator’s manual is readily available to excavators operating in LA.
5. 811 Board Composition Unbalanced:
a. The Louisiana 811 Board is not specifically addressed in the dig law, is not well designed, and is unbalanced among stakeholders including excavator, regulator, and locator representation.
6. 2014, 2017-2019, and 2019/2020 PHMSA Assessments Highlighting Gaps & Weaknesses:
a. 2014 Statewide Damage Prevention Programs and the Nine Elements Assessment – Multiple areas of improvement noted.
b. 2017, 2018, 2019 Gas State Program Evaluation – State rating of below 100 in all three years with multiple gaps and weaknesses pointed out.
c. 2020 State Damage Prevention Enforcement Program Assessment - State rating of “qualified adequate” with specific recommendations made.
7. Recent Damage Prevention Law Update:
a. House Bill 382 White lining and positive response required in dig law beginning in 2022.
Publisher’s observation:
Progress is being made in Louisiana and the PHMSA audit reflects the progress with the rating of “adequate.” However, to take the program to
the next level, stakeholders (all stakeholders) must get involved in this critical discussion.
The full report can be accessed by clicking on www.ipcweb.org and clicking on the state you want to view on the interactive map. As you consider this assessment and recommendations for Louisiana, you conclude one of two things. The evaluation of Louisiana’s damage prevention program is wrong and should remain as is or it is valid, and some changes need to be made.
Recognizing the need to change is the first step. The second step is accepting responsibility for our behaviors. The third step is knowing the desired behaviors. What’s the next step, Louisiana?
We’re waiting for your answer... If not us, who? If not now, when?
from Brent Saltzman
My response to the IPC
811 Emergency Report and recommendations as it specifically relates to Louisiana.
1. Mandatory Damage Reporting
will have to be imposed through the Dig Law. I, personally, am in favor of mandatory damage reporting and feel as though it would aid in our advertising/outreach efforts if we knew where the most damages are occurring.
2. Balanced Enforcement is
the same as above, but I think
we already have that to some
extent with the efforts of the LA Department of Natural Resources- Office of Conservation (DNR).
They seem to be very fair towards contractors and facility operators when assessing responsibility for Dig Law violations and damages.
3. Third-Party Enforcement Board
is something that was discussed
at length some time ago and I somewhat like the idea, but it’ll be tough to push through. In theory, overall enforcement across the board for all utilities makes sense but it needs to be fair to all stakeholders (excavators, locators and members). I do like the fact that DNR is proactive regarding enforcement and third- party enforcement boards tend to be reactive and only complaint driven. Again, another Dig Law change would be necessary.
4. Effective Metrics is something I’m unclear on. We do have the ability for folks to submit damages through our LA Virtual DIRT but not many folks take advantage of that. We, as an organization, track
a ton of information as a way of improving as a whole so I’m not sure what else we can do unless damage reporting is mandatory.
5. Positive Response has been enacted legislatively and has already been addressed for “all clear” situations but not for “locate complete” instances.
6. (A) White-lining too has been enacted legislatively and has been addressed. (B) Requiring GIS from all asset owners will be virtually impossible in my opinion. We have hundreds of small members who don’t have the financial resources to do this so who will fund it unless it’s federally subsidized? No one!
7. Standard ticket size is something we already have in place regarding distance (board governed), duration and life. All of these are already covered under the Dig
Law but a “large project” ticket is something our Board of Directors is looking into.
8. Educational Resources is something we already have as well. You can view our excavator tri-fold safety brochure on our website in English & Spanish and hard copies are available upon request. DNR also distributes these regularly while traversing the state and our staff always has these available at conferences and meetings we attend. Another online resource is our Excavator Training & Education course that is free for anyone and can be found on our website.
Overall, I feel as though there are several inaccuracies in the report but some points certainly have some merit. I would strongly encourage any stakeholder to get involved
in the process if they want to see change. If the change involves legislation, I’d urge folks to attend a Dig Law Advisory Committee Meeting and voice their opinion.
20 • Louisiana 811 2022, Issue 3